Privacy Policy

1. Introduction

This Privacy Policy explains how INSTASWICH LIMITED ("InstaSwich", "we", "us") processes personal data when you visit instaswich.com, contact our team, subscribe to our market intelligence, enrol in our education programmes, apply for a role, or engage us for business development and Introducing Broker services. InstaSwich is jointly managed with Novel Charts LTD and Trade Novela Limited, which act as joint controllers for the corporate services described on this website.

We apply the standards of the Nigeria Data Protection Act 2023 (NDPA) and, where our services reach data subjects in the United Kingdom or European Economic Area, the UK GDPR and EU GDPR. Where local law grants stronger protection than this policy, local law prevails.

2. Who is responsible for your data

The controller is INSTASWICH LIMITED (CAC RC 9737253), 20 2nd Avenue, Olorunsogo Yewa, Ikorodu, Lagos State, Nigeria. Data protection enquiries can be sent to support@instaswich.com or by telephone on +234 201 330 6182.

3. Categories of personal data we collect

3.1 Data you give us

• Identity data: full name, date of birth where required for verification, nationality and country of residence.
• Contact data: email address, telephone or WhatsApp number, Telegram handle and postal address.
• Commercial data: plan selected, education programme, invoices, receipts and payment references.
• Enquiry data: the content of contact forms, call-back requests, live-chat handovers and attachments you upload.
• Recruitment data: CV, employment history, qualifications and references submitted through our careers pages.
• Verification data: identification documents and proof of address supplied under our KYC Policy.

3.2 Data we collect automatically

• Device and technical data: IP address, browser type, operating system, language and screen characteristics.
• Usage data: pages viewed, referring URL, campaign parameters (UTM), scroll depth and interaction events.
• Cookie and storage identifiers, as described in our Cookie Policy.

3.3 Data from third parties

• Payment confirmation and transaction status from our payment processor.
• Broker partners, where you consent to an introduction, confirming account opening or activity status.
• Sanctions, PEP and adverse-media screening providers used for compliance checks.

We do not intentionally collect special-category data (health, biometrics, political or religious beliefs). Please do not include such information in free-text fields or attachments.

4. Why we process your data and the lawful basis

• To deliver the services you request — subscriptions, signals, education access, funding assistance and introductions. Basis: performance of a contract.
• To respond to enquiries and provide support, including call-backs and reference tracking. Basis: contract or legitimate interests.
• To take payment and issue invoices and receipts. Basis: contract and legal obligation.
• To meet compliance obligations — AML/CFT screening, record keeping, sanctions checks and regulatory reporting. Basis: legal obligation and substantial public interest.
• To secure the platform, prevent fraud, spam and abuse, including rate limiting and malware scanning of uploads. Basis: legitimate interests.
• To improve the website using aggregated analytics and campaign attribution. Basis: consent, where cookies require it, otherwise legitimate interests.
• To send service and marketing communications. Basis: consent for marketing; contract for service messages. You can opt out of marketing at any time.
• To evaluate job applications. Basis: steps prior to entering an employment contract.

5. Marketing preferences

Marketing emails carry an unsubscribe link in every message and we honour opt-outs promptly. Withdrawing marketing consent does not stop transactional messages such as receipts, renewal notices, security alerts or replies to your enquiries.

6. Sharing your data

We share personal data only where necessary, and always under contract, with:

• Payment processors and banking partners, to collect payments and confirm transactions.
• Email, hosting, database, analytics and customer-messaging providers acting as our processors.
• Broker partners, only where you have asked to be introduced or to receive funding assistance.
• Professional advisers — auditors, lawyers and accountants — bound by professional confidentiality.
• Law enforcement, regulators or courts, where disclosure is legally required or permitted.
• A purchaser or successor entity in the event of a reorganisation, merger or transfer of business.

We do not sell personal data and we do not share it with data brokers.

7. International transfers

Our infrastructure and service providers may process data outside your country of residence, including in the United Kingdom, the European Union and the United States. Transfers are protected by adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or equivalent safeguards recognised under the NDPA. A copy of the relevant safeguard is available on request.

8. Retention

• Enquiry and support records: up to 24 months after the last contact.
• Customer, subscription and billing records: at least 6 years, to satisfy tax and accounting obligations.
• KYC and AML records: at least 5 years after the end of the relationship, or longer if required by law.
• Unsuccessful job applications: 12 months, unless you ask us to keep them on file for future openings.
• Analytics data: retained in aggregate; identifiers expire in line with our Cookie Policy.

When a retention period ends we delete the data or irreversibly anonymise it.

9. Security

We use encryption in transit and at rest, strict role-based access controls, row-level database security, malware screening of uploaded files, audit logging of administrative actions, and least-privilege service credentials. No system is perfectly secure; where a breach is likely to result in a risk to your rights we will notify the relevant supervisory authority and, where required, you, without undue delay.

10. Your rights

Subject to legal limits, you may exercise the following rights free of charge:

• Access — obtain a copy of the personal data we hold about you.
• Rectification — correct inaccurate or incomplete data.
• Erasure — request deletion where we no longer need the data and no legal obligation requires retention.
• Restriction and objection — including objection to processing based on legitimate interests or to direct marketing.
• Portability — receive certain data in a structured, machine-readable format.
• Withdraw consent — at any time, without affecting processing carried out before withdrawal.
• Complain — to the Nigeria Data Protection Commission, the UK Information Commissioner's Office, or your local supervisory authority.

Send requests to support@instaswich.com. We respond within 30 days and may ask for proof of identity before disclosing personal data.

11. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you by automated means alone. Compliance screening may be automated, but any adverse outcome is reviewed by a person before action is taken.

12. Children

Our services are for adults aged 18 and over. We do not knowingly collect data from children. If you believe a minor has provided us data, contact us and we will delete it.

13. Third-party links and embeds

Our pages may link to or embed third-party services such as broker websites, TradingView charts, Telegram and WhatsApp. Their processing is governed by their own privacy policies, which we encourage you to read.

14. Changes to this policy

We review this policy at least annually and whenever our processing changes materially. The "last updated" date above always reflects the current version, and significant changes are announced on this page.

15. Contact

INSTASWICH LIMITED · support@instaswich.com · +234 201 330 6182. See also our Terms & Conditions, Cookie Policy and Risk Disclosure.